ORIGINAL Before the

FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554

In the Matter of

Amendment of Section 73.622(i) Post-Transition Table of Allotments, Digital Television Broadcast Stations (Florence, South Carolina)

To: Office of the Secretary Attn: Chief, Video Division

Media Bureau

) ) ) ) ) )

MB Docket No. RM-

--------

TED F\LEOI AGeE? .

fEB - 3 7Q,7 , im . cations COffii1\ISS L

Federal ~~~~~~~e secretary

SUPPLEMENT TO PETITION FOR RULE MAKING TO AMEND THE TABLE OF DTV ALLOTMENTS

By its attorneys and pursuant to Sections 1.401, 73.616, and 73.622(a) of the

Commission's Rules,! Media General Communications Holdings, LLC ("Licensee"), licensee of

WBTW(TV), Florence, South Carolina (the "Station"), hereby submits this Supplement to the

Petition for Rule Making filed on May 2, 2011, to provide information demonstrating how

Licensee's proposal advances the public interest.

In the Petition, Licensee requested that the Commission institute a rulemaking to amend

Section 73.622(i), the Post-Transition Table ofDTV Allotments, by substituting Channel 41 as

the Station's allotment in lieu of Channel 13. The Petition explained that, by changing from

VHF Channel 13 to UHF Channel 41, Licensee would be able to more meaningfully replicate the

Station's traditional analog service area and provide more reliable service for viewers within the

Station's service area.

47 C.F.R. §§ 1.401, 73.616, 73.622(a).

With this Supplement, Licensee provides additional infonnation demonstrating that

operation on Channel 41 would cause only a de minimis loss of service and viewers in the loss

area would remain well served. As shown in the attached Technical Statement, according to the

Commission's OET-69 model, operation on Channel 41 will cause only 3,484 viewers

(approximately 0.2% of the service area) to lose service. Moreover, all of the viewers in the

predicted loss area will remain well served because all will continue to receive at least one CBS

affiliate over the air. The benefits from the improved, more reliable service from operating on

UHF Channel 41 far outweighs the de minimis loss of service to viewers who will continue to

have access to other sources of CBS programming.2

For the reasons set forth in the Petition and this Supplement, Licensee respectfully

requests that the Commission amend the Post-Transition Table ofDTV Allotments as proposed.

As noted initially, adoption would serve the public interest by pennitting the Station to provide a

more meaningful replication of service. In addition, because this proposal would allow for more

reliable and improved service within the Station's service area, Licensee respectfully requests

that the Commission find that good cause exists under Section 553(d)(3) of the Administrative

Procedures Act (5 U.S.C. § 553(d)(3)) to make this change effective immediately upon

publication in the Federal Register of a Report and Order in this proceeding.3

2 KNTV License, Inc., 19 FCC Rcd 15479, 15485 n.11 (MB 2004) ("We are less concerned about the withdrawal of service here [to 21,170 viewers], because the vast majority ofthe people located within the loss area will continue to receive NBC network service from other NBC affiliates, and are also well served by other stations.").

3 See, e.g., Ann Arbor, Michigan, 24 FCC Rcd 10856, 10857 (MB 2009) ("An expedited effective date is necessary in this case to ensure that station WPXD-TV can provide improved service to its market as quickly as possible."). See also Bismark, North Dakota, 24 FCC Rcd 7534 (MB 2009); St. Paul, Minnesota, 24 FCC Rcd 8953 (MB 2009); Bryan, Texas, 24 FCC Rcd 4867 (MB 2009).

- 2 -

Dated: February 3, 2012

Respectfully submitted,

COMMUNICATIONS

By ____ ~~~~~~~-------------M. Swanson Robert J. Folliard, III

of

Dow Lohnes PLLC

1200 New Hampshire Avenue, N.W., Suite 800 Washington, D.C. 20036-6802 (202) 776-2534

Its Attorneys

-3-

ATTACHMENT A

Technical Exhibit

du Treil, Lundin & Rackley, Inc. _ __________________________________ Consulting Engineers

SUPLEMENT TO TECHNICAL EXHIBIT PETITION FOR RULE MAKING TO

MODIFY THE DTV TABLE OF ALLOTMENTS STATION WBTW(TV)

FLORENCE, SOUTH CAROLINA

This Supplement to the Technical Exhibit was prepared on behalf of television

station WBTW (TV) assigned to Florence, South Carolina in support of a Petition for Rule

Making to modify the DTV allotment of WBTW to substitute UHF channel 41 for the current

VHF channel 13 DTV allotment.

Figure 1 is a map showing the predicted noise limited contours for the present

and proposed WBTW digital television operations. The extent of the contours is calculated

using the FCC's standard prediction method along 36 evenly spaced radials with a 3 second

digitized terrain database. The predicted 36 dBu contour is shown for the present WBTW

operation on channel 13 (31.6 kW-ND, 598 m), and the predicted 41 dBu contour is shown for

the proposed WBTW operation on channel4l (1000 kW-ND, 598 m). As shown on Figure 1,

the proposed WBTW channel 41 contour substantially replicates the present channel 13

contour.

Figure 3 is a printout from the FCC's OET -69 computer program that

calculates the service population for the present WBTW operation using the OET -69 model

and the 2000 US Census. As shown, the present WBTW service population is 1,695,034

people. Figure 4 is a similar showing for the proposed WBTW operation on channel 41

(1,691,550 people). The proposed WBTW operation on channel 41 is calculated to provide

service to 3,484 fewer people than the present WBTW operation on channel 13.

The following are estimates of the population (2000 US Census) within the 2

predicted noise limited contours shown on Figure 1.

Present WBTW Ch.13, 36 dBu

Proposed WBTW Ch.41, 41 dBu

1,763,862 people

1,702,268 people

du Treil, Lundin & Rackley, Inc. ____________________________________ ConsultingEngineers

Predicted loss area 61,594 people

Florence, South Carolina Page 2

Station WBTW is a CBS television network affiliate. Figure 2 is a map

showing the present and proposed WBTW noise limited contours, and the contours for other

CBS television network affiliates providing service to the predicted loss area. The following

are the other CBS television network affiliates shown on Figure 2.

WBTV, Ch.23, Charlotte, NC.

WFMY-TV, Ch.51, Greensboro, NC.

WNCT-TV, Ch.1O, Greenville, NC.

WNCT -DR, PRM, Ch.45, Greenville, NC.

WRAL-TV, Ch.48, Raleigh, NC.

WILM-LD, Ch.40, Wilmington, NC.

WCSC-TV, Ch.47, Charleston, SC.

WLTX, Ch.17, Columbia, Sc.

As shown on Figure 2, there is no land area that would be predicted to lose WNCT CBS

network service. Hence, there is no population loss for CBS network service.

John A. Lundin

du Treil, Lundin & Rackley, Inc. 201 Fletcher Avenue Sarasota, Florida 34237 (941) 329-6011

February 2,2012

-25 o 2S so 75 100

Kilometre

Figure 1

Assumed WBTIN Ch, 41 , 1000 kW, 598 m

41 dBu, f(50,90) (dashed line)

Present WBTW Ch. 13, 31 .6 kW, 598 m

36 dBu, f(50,90) (solid line)

125

FCC PREDICTED NOISE-LIMITED COVERAGE CONTOURS

duTreil, Lundin & Rackley, Inc. Sarasota, Florida

or

"''''

-50 o 50 100

Kilometres

Figure 2

WBTW, Florence, SC Present Ch. 13, 36 dBu (solid )

~---1 Assumed Ch. 41 , 41 dBu (dashed)

150

All population within lhe WBTW loss area Is served by at least one other CBS net'NOrk affiliated stalion.

200

OTHER CBS NETWORK SERVICES TO WBTW PREDICTED LOSS AREA

duTreil, Lundin & Rackley, Inc. Sarasota, Florida

Percent allowed new interference: 0.500 Percent allowed new interference to non Class A LPTV: 2.000

TW Census data selected 2000 Data Base Selected /export/home/cdbs/pt tvdb.sff

TV INTERFERENCE and SPACING ANALYSIS PROGRAM

Date: 01-31-2012 Time: 12:35:29

Record Selected for Analysis

WBTW BLCDT -20090612AIR FLORENCE Channel 13 ERP 31.6 kW HAAT 00598 m RCAMSL 00629 m Latitude 034-22- 4 Longitude 0079-19-21 Status LIC Zone 2 Border Site number: 01 Last update 00000000 Cutoff date 00000000 Docket Comments Applicant MEDIA GENERAL COMMUNICATIONS HOLDING

Cell Size for Service Analysis 2.0 km/side

Distance Increments for Longley-Rice Analysis 1.00 km

Facility (site # 01) meets maximum height/power limits

Site number 1 Azimuth ERP HAAT 36.0 dBu F (50,90)

(Deg) (kW) (m) (km) 0.0 31.600 592.0 122.8

45.0 31.600 591.8 122.8 90.0 31.600 598.0 123.3

135.0 31.600 606.7 123.8 180.0 31.600 599.8 123.4 225.0 31.600 601.9 123.5 270.0 31.600 599.3 123.3 315.0 31.600 595.0 123.1

Evaluation toward Class A Stations from site

Contour overlap to Class A station WUBX-CA 13 DURHAM, ETC. NC BLTVL 19930223ID

Contour overlap to Class A station WBXU-CA 13 RALEIGH NC BLTVA 20020321AAD

Class A Evaluation Complete

Checks to Site Number 01

Proposed facility OK to FCC Monitoring Stations

Proposed facility OK toward West Virginia quiet zone

SC US

# 01

Figure 3 Sheet 1 of 2

Proposed facility OK toward Table Mountain

Proposed facility is beyond the Canadian coordination distance

Proposed facility is beyond the Mexican coordination distance

Proposed station is OK toward AM broadcast stations

Figure 3 Sheet 2 of 2

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Analysis of Interference to Affected Station 9

Analysis of current record Channel Call City/State

FLORENCE SC Application Ref. No.

13 WBTW BLCDT -20090612AIR

Stations Potentially Affecting This Station

Chan Call City/State Dist(km) Status Application Ref. No. 12 WCTI-TV NEW BERN NC 199.0 LIC BLCDT 13 WLOS ASHEVILLE NC 334.4 CP BPCDT 13 WLOS ASHEVILLE NC 334.4 CP MOD BMPCDT 13 WLOS ASHEVILLE NC 334.4 LIC BLCDT 13 WVEC HAMPTON VA 375.0 LIC BLCDT 13 WSET-TV LYNCHBURG VA 328.8 LIC BLCDT

Total scenarios 3

Result key: 3 Scenario 3 Affected station 9 Before Analysis

Results for: 13A SC FLORENCE BLCDT 20090612AIR HAAT 598.0 m, ATV ERP 31. 6 kW

POPULATION AREA (sq km) within Noise Limited Contour 1768009 47722.0 not affected by terrain losses 1755603 47055.8 lost to NTSC IX 0 0.0 lost to additional IX by ATV 60569 1619.7 lost to ATV IX only 60569 1619.7 lost to all IX 60569 1619.7 ---

Service Population 1695034

Potential Interfering Stations Included in above Scenario 3

13A NC ASHEVILLE 13A VA HAMPTON 13A VA LYNCHBURG

BLCDT BLCDT BLCDT

20101014ABR LIC 20090612AJJ LIC 20091013ABE LIC

-20090622ADO -20080317AGL -20080620AKA -20101014ABR -20090612AJJ -20091013ABE

LIC

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FINISHED FINISHED FINISHED FINISHED FINISHED FINISHED

Percent allowed new interference: 0.500 Percent allowed new interference to non Class A LPTV:

TW Census data selected 2000 Data Base Selected /export/home/cdbs/pt_tvdb.sff

2.000

TV INTERFERENCE and SPACING ANALYSIS PROGRAM

Date: 01-31-2012 Time: 12:25:59

Record Selected for Analysis

WBTW-DR BPRM -20110502AEV FLORENCE Channel 41 ERP 1000. kW HAAT 00598 m RCAMSL 00629 m Latitude 034-22- 4 Longitude 0079-19-21 Status APP Zone 2 Border Site number: 01 Last update 00000000 Cutoff date 00000000 Docket Comments Applicant MEDIA GENERAL COMMUNICATIONS HOLDING

Cell Size for Service Analysis 2.0 km/side

Distance Increments for Longley-Rice Analysis 1.00 km

SC US

Facility (site # 01) does not meet maximum height/power limits Channel 41 ERP 1000.00 HAAT = 598.

Site number Azimuth

1 ERP (kW)

HAAT 41.0 dBu F(50,90) (Deg) 0.0

45.0 90.0

135.0 180.0 225.0 270.0 315.0

1000.000 1000.000 1000.000 1000.000 1000.000 1000.000 1000.000 1000.000

(m)

592.0 591.8 598.0 606.7 599.8 601.9 599.3 595.0

(km) 120.1 120.1 120.5 121.0 120.6 120.7 120.5 120.3

Evaluation toward Class A Stations from site # 01

No Spacing violations or contour overlap to Class A stations from site # 01

Class A Evaluation Complete

Checks to Site Number 01

Proposed facility OK to FCC Monitoring Stations

Proposed facility OK toward West Virginia quiet zone

Proposed facility OK toward Table Mountain

Figure 4 Sheet 1 of 2

Proposed facility is beyond the Canadian coordination distance

Proposed facility is beyond the Mexican coordination distance

Proposed station is OK toward AM broadcast stations

Figure 4 Sheet 2 of 2

************************************************************************

Analysis of Interference to Affected Station 6

Analysis of current record Channel Call City/State

FLORENCE SC Application Ref. No.

41 WBTW-DR BPRM -20110502AEV

Stations Potentially Affecting This Station

Chan Call City/State Dist(km) Status Application Ref. No. 40 WHKY-TV HICKORY NC 161.7 CP MOD BMPCDT -20090310ADE 41 WETP-TV SNEEDVILLE TN 42 WRAY-TV WILSON NC 40 WHKY-TV HICKORY NC

Total scenarios 1

Result key: 1

Scenario 1 Affected station Before Analysis

Results for: 41A SC FLORENCE HAAT 598.0 m, ATV ERP 1000.0 kW

415.1 LIC 194.6 LIC

BLEDT BLCDT

CP MOD BMPCDT

6

BPRM 20110502AEV

POPULATION AREA (sq km) within Noise Limited Contour 1694284 45160.5 not affected by terrain losses 1691550 44909.2 lost to NTSC IX 0 0.0 lost to additional IX by ATV 0 0.0 lost to ATV IX only 0 0.0 lost to all IX 0 0.0

Service Population 1691550

Potential Interfering Stations Included in above Scenario 1

-20050916AAX -20060609AAX -20090310ADE

APP

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FINISHED FINISHED FINISHED FINISHED FINISHED FINISHED